7 Reasons the New OSHA Walking Working Surfaces Rule Will Affect You
Last November was a game-changer: the OSHA walking working surfaces final rule was updated for the first time in decades. The final rule, says Dr. David Michaels, will “reduce worker deaths and injuries from falls” for 112 million workers at 7 million worksites across the United States.
What's New in the OSHA Walking Working Surfaces Final Rule?
But let’s back up. If you’re a new building owner or facility manager, you may be uncertain about the original standards -- let alone the 2016 updates. The ruling affects more workers than you may realize, from general maintenance to window washers, painters, and outdoor advertising workers. Here are seven key points about the OSHA walking working surfaces final rule, and how they might affect you and your business.
#1: It’s already in effect.
The OSHA walking working surfaces final rule became active in January 17, 2017 -- but the good news is that this deadline mostly pertains to the existing standards, rather than the revised ones. In short, if you’ve kept your organization up to OSHA standards over the years, you’re probably not at risk for a citation (yet!).
However, you’ll still need to ensure you’re fulfilling the new Subpart D requirements. Here’s a look at the deadlines for implementing each new item, according to the Federal Register:
|Deadline||Requirement||Subpart D Section|
|May 17, 2017||Deadline by which employers must train employees on fall and equipment hazards.||1910.30 (a) and (b)|
|November 20, 2017||Testing & certification of anchorages.||1910.27 (b)(1)|
|November 19, 2018||Deadline by which employers must equip existing fixed ladders with one of the following solutions: cage, well, ladder safety system, or personal fall arrest system.||1910.28(b)(9)(i)(A)|
|November 19, 2018||After this date, employers must begin equipping new & renovated fixed ladders with a ladder safety system or personal fall arrest system.||1910.28 (b)(9)(i)(B)|
|November 18, 2036||Deadline by which all fixed ladders must be equipped with a ladder safety system or personal fall arrest system in place of cages and wells.||1910.28(b)(9)(i)(D)|
#2: The final rule may provide more flexibility for some employers.
The language used in the final rule is “performance-based” rather than specification-based, meaning there’s more room for knowledgeable employers to select the equipment and controls that “will be most effective in the particular workplace operation or situation.”
Not only does this make it easier to read OSHA’s new rule, but it allows employers more freedom in selecting the type of equipment they want to use. In fact, workers can use non-conventional fall protection -- like a designated area -- in instances where work is temporary and danger is limited.
#3: Rope descent systems rules are more stringent.
Here’s a new responsibility for building owners: in section 1910.27(b), the text states that owners must inform employers in writing that each anchorage point has been certified as capable of holding at least 5,000 pounds in any direction per person attached. Further, each anchorage must be inspected each year thereafter and re-certified every 10 years.
Workers are also prohibited from using rope descent systems at heights greater than 300 feet (unless the employer can demonstrate that it is not feasible to access such height by any other means, or that those means pose a greater hazard than using a rope descent system), and in poor weather conditions. The rope must be inspected at the beginning of a shift, and should be kept away from sharp edges or padded where they might contact surfaces that could weaken or cut them.
#4: Ladder requirements are also a bit steeper.
Though much of the OSHA requirements for portable and fixed ladders seems like common sense (don’t prop a ladder up on an unstable surface), there are additional provisions in the new rule. The text states that fixed ladders require a specific distance between rungs and away from other objects, as do parapets, side rails, ladder wells, and mobile ladder stands. For a complete list of ladder requirements, check out section 1910.23.
#5: Unprotected edges need attention.
When workers are faced with unprotected edges, employers now have to provide protection in many cases, according to 1910.25. The general rule is that any side or edge that’s four feet up from a lower level requires some sort of protection. Though the rule states specific details for different situations, there has to be at least one of the following types of precautions in place:
- Guardrail system
- Safety net system
- Personal fall arrest system
- Positioning system
- Travel restraint system
#6: Training is key.
Employers must train all employees about recognizing fall hazards. They should also know the right procedures to minimize those hazards -- for instance, moving cords or tools out of the way to avoid a trip hazard. According to section 1910.30, employees should also know:
- How to use a fall protection system, including hook-up, anchoring, and tie off techniques of personal fall protection gear
- How to install and disassemble a fall protection system
- How to inspect and maintain a fall protection system
It’s up to the employer, not the worker, to ensure that all employees are educated on fall protection and arrest equipment and procedures. It’s also the employer’s responsibility to retrain workers as needed, and provide information in a “manner that the employee understands.” This could mean translating training sessions into another language or accommodating a disability.
Finally, the trainer should be what OSHA defines as a “qualified person” -- meaning they have a recognized degree, certificate, or professional standing as a master of the work or project in question.
#7: The new rule incorporates many existing industry standards.
The new rule is OSHA’s first official update since 1972, and much has changed over these 40 years. Though ANSI and other industry standards have been guiding the behavior of workers for decades, OSHA’s rule makes these best practices official and carry the force of law.
In the Federal Register, OSHA states that they agree with stakeholders these “consensus standards represent industry best practices and reflect advancements in technology, methods, and practices developed in the years since the Agency adopted the existing rule.” In essence, OSHA’s final rule is catching up to modern times, when technology (when used properly) can provide safer workplaces.
It’s quite a bit of information to take in, but OSHA insists these changes are for the best, estimating that this rule will prevent “29 fatalities and 5,842 injuries annually.”
For further reading on these standards, check out the resources below.
OSHA Final Rule press release:
OSHA FAQ page:
Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) Full Text:
Rooftop Anchor is an industry leader in OSHA-compliant fall protection systems. Call us today at 800-411-3914 to talk about your project, or schedule a free appointment using our online scheduler.
Rooftop Anchor is an industry leader in OSHA-compliant fall protection systems. For more information, download our free OSHA deadline PDF and fall protection map here, or call us at 800-411-3914 to talk about your project. Ready to meet? Use our online scheduler to set up an appointment.